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CARES Act: Employee Benefit Plans

March 27, 2020

The Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”), which was signed into law on March 27, 2020, expand employee benefit plan opportunities through the relaxation of certain requirements (including under the Internal Revenue Code (“Code”) and the Employee Retirement Income Security Act (“ERISA”) for retirement plans, health plans and certain medical reimbursement accounts. Plan sponsors should carefully review plan documentation to consider implications on their benefit offerings and administration.

Retirement Plans

Health Plan and Medical Reimbursement Account Issues

The CARES Act also expands the United States Department of Labor’s authority to postpone certain deadlines under ERISA. Accordingly, further relief for employee benefit plans may be forthcoming. Plan sponsors wishing to provide this coronavirus-related relief to plan participants should coordinate with their plan record keepers, custodians, trustees, insurance carriers, and administrators to facilitate operational and documental compliance with the CARES Act options. 

This is part of a series of our COVID-19 alerts providing clients with practical advice on measures they can take to navigate through these challenging times. Please contact the authors or your Miller Canfield attorney with further questions.

This information is based on the facts and guidance available at the time of publication, and may be subject to change.